Privacy Statement

Clarity4D is committed to protecting your privacy and developing technology that gives you the most powerful and safe online experience. This Statement of Privacy applies to the Clarity4D Web site and governs data collection and usage. By using the Clarity4D website, you consent to the data practices described in this statement.

Collection of your Personal Information

Clarity4D collects personally identifiable information, such as your e-mail address, name, home or work address or telephone number. Clarity4D also collects anonymous demographic information, which is not unique to you, such as your ZIP code, age, gender, preferences, interests and favorites.

There is also information about your computer hardware and software that is automatically collected by Clarity4D. This information can include: your IP address, browser type, domain names, access times and referring Web site addresses. This information is used by Clarity4D for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Clarity4D Web site.

Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through Clarity4D public message boards, this information may be collected and used by others. Note: Clarity4D does not read any of your private online communications.

Clarity4D encourages you to review the privacy statements of Web sites you choose to link to from Clarity4D so that you can understand how those Web sites collect, use and share your information. Clarity4D is not responsible for the privacy statements or other content on Web sites outside of the Clarity4D and Clarity4D family of Web sites.

Use of your Personal Information

Clarity4D collects and uses your personal information to operate the Clarity4D Web site and deliver the services you have requested.

Clarity4D does not sell, rent or lease its customer lists to third parties.  In addition, Clarity4D may share data with trusted partners to help us perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to Clarity4D, and they are required to maintain the confidentiality of your information.

Clarity4D does not use or disclose sensitive personal information, such as race, religion, or political affiliations, without your explicit consent.

Clarity4D keeps track of the Web sites and pages our customers visit within Clarity4D, in order to determine what Clarity4D services are the most popular. This data is used to deliver customized content and advertising within Clarity4D to customers whose behavior indicates that they are interested in a particular subject area.

Clarity4D Web sites will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Clarity4D or the site; (b) protect and defend the rights or property of Clarity4D; and, (c) act under exigent circumstances to protect the personal safety of users of Clarity4D, or the public.

Use of Cookies

The Clarity4D Web site use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a Web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize Clarity4D pages, or register with Clarity4D site or services, a cookie helps Clarity4D to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same Clarity4D Web site, the information you previously provided can be retrieved, so you can easily use the Clarity4D features that you customized.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Clarity4D services or Web sites you visit.

Security of your Personal Information

Clarity4D secures your personal information from unauthorized access, use or disclosure. Clarity4D secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When personal information (such as a credit card number) is transmitted to other Web sites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

Clarity4D Data Protection Policy

Clarity4D will not use any personal information for any unauthorised purpose (including marketing) and will keep all personal information secure. Clarity4D will not share personal information with third parties unless this is required to allow us to provide the services that the data subject have requested and only where all parties comply with the relevant data protection and privacy laws.

Clarity4D is registered with the UK Information Commissioner’s Office (ICO), an independent authority set up to uphold data privacy. The ICO is internationally recognised as being at the forefront of the protection of personal information.

ICO Registration Number: ZA102494

Why this Policy exists

This data protection policy ensures:

• Complies with data protection law and follow good practice

• Protects the rights of staff, customers and partners

• Is open about how it stores and processes individuals’ data

• Protect itself from the risks of a data breach

General Data Protection Regulation

The GDPR is underpinned by six important principles. These say that personal data must:

1) Processed lawfully, fairly and in a transparent manner in relation to individuals;

2) Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes

3) Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

4) Accurate and, where necessary, kept up to date; every reasonable step will be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are deleted or corrected;

5) Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;

6) Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

Policy Scope

This policy applies to:

• The head office of Clarity4D

• All staff of Clarity4D

• All Business Partners and other people working on behalf of Clarity4D

It applies to all data that the company holds relating to identifiable individuals, even if that

information technically falls outside of the Data Protection Act 1998. This can include:

• Names of individuals

• Postal addresses

• Email addresses

• Telephone numbers

• Employment status

Data Protection Risks

This policy helps to protect Clarity4D from some very real data security risks, including:

• Breaches of confidentiality

• Failing to offer choice

• Reputational damage

Responsibilities

Everyone who works for or with Clarity4D has some responsibility for ensuring data is collected,stored and handled appropriately. However, the board of directors is ultimately responsible for ensuring that Clarity4D meets its legal obligations.

Clarity4D will take “appropriate technical and organisational measures” against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.

General Staff Guidelines

• Clarity4D will provide training to all employees and Business Partners to help them understand their responsibilities when handling data.

• Employees and Business Partners should keep all data secure, by taking sensible precautions and following the guidelines below

• In particular, strong passwords must be used, and they should never be shared.

• Personal date should not be disclosed to unauthorised people, either within the company or externally.

• Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.

• Employees and Business Partners should request help from the IT Director if they are unsure about any aspect of data protection.

Disclosing data for other reasons

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances, Clarity4D will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the Board and from the company’s legal advisers were necessary.

Rights of Data Subjects

The rights of data subjects under GDPR requires that Clarity4D will adhere to the following with 30 days receiving the request:

1. Right of access to personal data – a data subject can request the following in writing:

• Confirmation as to whether the data controller process their personal data;

• A copy of their personal data;

• Details of the purpose for which it is processed;

• Details of any recipients, or classes of recipients, to whom their personal data may be disclosed; and

• The source(s) of the personal data.

2. Right to prevent processing likely to cause damage or distress – for this right to apply the damage or distress must be unwarranted and substantial, and can be to the data subject or another. A request must be in writing and actioned within 30 days.

3. Right to be forgotten – data subjects have a right to request the deletion of their data.

Clarity4D reserve the right to not delete such data, if the data is needed to comply with a legal or business obligation.

Changes to this Statement

Clarity4D will occasionally update this Statement of Privacy to reflect company and customer feedback. Clarity4D encourages you to periodically review this Statement to be informed of how Clarity4D is protecting your information.

Contact Information

Clarity4D welcomes your comments regarding this Statement of Privacy. If you believe that Clarity4D has not adhered to this Statement, please contact Clarity4D at admin@change.me. We will use commercially reasonable efforts to promptly determine and remedy the problem.

Clarity4D Equality Policy

Clarity4D is committed to encouraging equality and diversity among our workforce, and eliminating unlawful discrimination.

The aim is for our workforce to be truly representative of all sections of society and our customers, and for each employee to feel respected and able to give their best.

The organisation – in providing goods and/or services and/or facilities – is also committed against unlawful discrimination of customers or the public

The policy’s purpose is to:

·   provide equality, fairness and respect for all in our employment, whether temporary, part-time or full-time

·   not unlawfully discriminate because of the Equality Act 2010 protected characteristics of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality, and ethnic or national origin), religion or belief, sex (gender) and sexual orientation

·   oppose and avoid all forms of unlawful discrimination. This includes in pay and benefits, terms and conditions of employment, dealing with grievances and discipline, dismissal, redundancy, leave for parents, requests for flexible working, and selection for employment, promotion, training or other developmental opportunities

Clarity4D commits to:

·   encourage equality and diversity in the workplace as they are good practice and make business sense

·   create a working environment free of bullying, harassment, victimisation and unlawful discrimination, promoting dignity and respect for all, and where individual differences and the contributions of all staff are recognised and valued

This commitment includes training managers and all other employees about their rights and responsibilities under the equality policy. Responsibilities include staff conducting themselves to help the organisation provide equal opportunities in employment, and prevent bullying, harassment, victimisation and unlawful discrimination

All staff should understand they, as well as their employer, can be held liable for acts of bullying, harassment, victimisation and unlawful discrimination, in the course of their employment, against fellow employees, customers, suppliers and the public

·   take seriously complaints of bullying, harassment, victimisation and unlawful discrimination by fellow employees, customers, suppliers, visitors, the public and any others in the course of the organisation’s work activities

Such acts will be dealt with as misconduct under the organisation’s grievance and/or disciplinary procedures, and any appropriate action will be taken. Particularly serious complaints could amount to gross misconduct and lead to dismissal without notice.

Further, sexual harassment may amount to both an employment rights matter and a criminal matter, such as in sexual assault allegations. In addition, harassment under the Protection from Harassment Act 1997 – which is not limited to circumstances where harassment relates to a protected characteristic – is a criminal offence

·   make opportunities for training, development and progress available to all staff, who will be helped and encouraged to develop their full potential, so their talents and resources can be fully utilised to maximise the efficiency of the organisation

·   decisions concerning staff being based on merit (apart from in any necessary and limited exemptions and exceptions allowed under the Equality Act)

·   review employment practices and procedures when necessary to ensure fairness, and also update them and the policy to take account of changes in the law

·   monitor the make-up of the workforce regarding information such as age, gender, ethnic background, sexual orientation, religion or belief, and disability in encouraging equality and diversity, and in meeting the aims and commitments set out in the equality policy

Monitoring will also include assessing how the equality policy, and any supporting action plan, are working in practice, reviewing them annually, and considering and taking action to address any issues .The equality policy is fully supported by the board of directors.

Judy Oliver                   Steve Davies           Hieu Phan